Lockheed Martin Code of Ethics and Business Conduct
Treat in an Ethical Manner Those to Whom Lockheed Martin Has an Obligation
For our employees we are committed to honesty, just management, fairness, providing a safe and healthy environment free from the fear of retribution, and respecting the dignity due everyone.
For our customers we are committed to produce reliable products and services, delivered on time, at a fair price.
For the communities in which we live and work we are committed to observe sound environmental business practices and to act as concerned and responsible neighbors, reflecting all aspects of good citizenship.
For our shareholders we are committed to pursuing sound growth and earnings objectives and to exercising prudence in the use of our assets and resources.
For our suppliers and partners we are committed to fair competition and the sense of responsibility required of a good customer and teammate.
We are committed to the ethical treatment of those to whom we have an obligation.
Obey the Law
We will conduct our business in accordance with all applicable laws and regulations. The laws and regulations related to government contracting are far-reaching and complex, thus placing responsibilities on Lockheed Martin beyond those faced by companies without government customers. Compliance with the law does not comprise our entire ethical responsibility. Rather, it is a minimum, absolutely essential condition for performance of our duties.
We will conduct our business in accordance with all applicable laws and regulations.
Promote a Positive Work Environment
All employees want and deserve a workplace where they feel respected, satisfied, and appreciated. As a global enterprise, we respect cultural diversity and recognize that the various countries in which we do business may have different legal provisions pertaining to the workplace. As such, we will adhere to the limitations specified by law in all of our localities, and further, we will not tolerate harassment or discrimination of any kind -- especially involving race, color, religion, gender, age, national origin, disability, and veteran or marital status.
Providing an environment that supports honesty, integrity, respect, trust, responsibility, and citizenship permits us the opportunity to achieve excellence in our workplace. While everyone who works for the Company must contribute to the creation and maintenance of such an environment, our executives and management personnel assume special responsibility for fostering a work environment that is free from the fear of retribution and will bring out the best in all of us. Supervisors must be careful in words and conduct to avoid placing, or seeming to place, pressure on subordinates that could cause them to deviate from acceptable ethical behavior.
Work Safely: Protect Yourself, Your Fellow Employees, and the World We Live In
We are committed to providing a drug-free, safe, and healthy work environment, and to observe environmentally sound business practices throughout the world. We will strive, at a minimum, to do no harm and where possible, to make the communities in which we work a better place to live. Each of us is responsible for compliance with environmental, health, and safety laws and regulations. Observe posted warnings and regulations. Report immediately to the appropriate management any accident or injury sustained on the job, or any environmental or safety concern you may have.
We are committed to providing a drug-free, safe, and healthy work environment.
Keep Accurate and Complete Records
We must maintain accurate and complete Company records. Transactions between the Company and outside individuals and organizations must be promptly and accurately entered in our books in accordance with generally accepted accounting practices and principles. No one should rationalize or even consider misrepresenting facts or falsifying records. It will not be tolerated and will result in disciplinary action.
No one should rationalize or even consider misrepresenting facts or falsifying records.
Record Costs Properly
Employees and their supervisors are responsible for ensuring that labor and material costs are accurately recorded and charged on the Company's records. These costs include, but are not limited to, normal contract work, work related to independent research and development, and bid and proposal activities.
Employees and their supervisors are responsible for... the Company's records.
Strictly Adhere to All Antitrust Laws
Antitrust is a blanket term for laws that protect the free enterprise system and promote open and fair competition. Such laws exist in the United States, the European Union, and in many other countries where the Company does business. These laws deal with agreements and practices "in restraint of trade" such as price fixing and boycotting suppliers or customers, for example. They also bar pricing intended to run a competitor out of business; disparaging, misrepresenting, or harassing a competitor; stealing trade secrets; bribery; and kickbacks.
Antitrust laws are vigorously enforced. Violations may result in severe penalties such a forced sales of parts of businesses and significant fines against the Company. There may also be sanctions against individual employees including substantial fines and prison sentences.
Know and Follow the Law When Involved in International Business
Corruption erodes confidence in the marketplace, undermines democracy, distorts economic and social development, and hurts everyone who depends on trust and transparency in the transaction of business. The Company is committed to conduct its activities free from the unfair influence of bribery and to foster anti-corruption awareness among its employees and business relations throughout the world. The Foreign Corrupt Practices Act (FCPA) is a United States law that prohibits corruptly giving, offering or promising anything of value to foreign officials or foreign political parties, officials or candidates, for the purpose of influencing them to misuse their official capacity to obtain, keep, or direct business or to gain any improper advantage. In addition, the FCPA prohibits knowingly falsifying a company's books and records or knowingly circumventing or failing to implement accounting controls. Employees involved in international operations must be familiar with the FCPA and with similar laws that govern our operations in other countries in which we do business.
International transfers of equipment or technology are also subject to laws and regulations -- such as the International Traffic in Arms Regulations (ITAR) in the United States -- that may contain prior approval, licensing, and reporting requirements.
Additionally, it is illegal to enter into an agreement to refuse to deal with potential or actual customers or suppliers, or otherwise to engage in or support restrictive international trade practices or boycotts.
It is always important that employees conducting international business know and abide by the laws of the countries which are involved in the activities or transactions. These laws govern the conduct of Lockheed Martin employees throughout the world. If you participate in these business activities, you should know, understand, and strictly comply with these laws and regulations. If you are not familiar with these rules, consult with your supervisor and the Legal Department prior to negotiating any foreign transaction.
Follow the Law and Use Common Sense in Political Contributions and Activities
Lockheed Martin encourages its employees to become involved in civic affairs and to participate in the political process. Employees must understand, however, that their involvement and participation must be on an individual basis, on their own time, and at their own expense. In the United States, federal law prohibits corporations from donating corporate funds, goods, or services, directly or indirectly, to candidates for federal offices -- this includes employees' work time. Local and state laws also govern political contributions and activities as they apply to their respective jurisdictions, and similar laws exist in other countries.
Carefully Bid, Negotiate, and Perform Contracts
We must comply with the laws and regulations that pertain to the acquisition of goods and services by our customers. We will compete fairly and ethically for all business opportunities. In circumstances where there is reason to believe that the release or receipt of non-public information is unauthorized, do not attempt to obtain and do not accept such information from any source.
Appropriate steps should be taken to recognize and avoid organizational conflicts in which one business unit's activities may preclude the pursuit of a related activity by another Company business unit.
If you are involved in proposals, bid preparations, or contract negotiations, you must be certain that all statements, communications, and representations to prospective customers are accurate and truthful. Once awarded, all contracts must be performed in compliance with specifications, requirements, and clauses.
Avoid Illegal and Questionable Gifts or Favors
The sale of Lockheed Martin products and services should always be free from even the perception that favorable treatment was sought, received, or given in exchange for the furnishing or receipt of business courtesies. Employees will neither give nor accept business courtesies that constitute, or could be reasonably perceived as constituting, unfair business inducements or that would violate law, regulation or policies of the Company or customer, or could cause embarrassment to or reflect negatively on the Company's reputation. Although customs and practices may differ among the many marketplaces in which we conduct our business, our policies in this regard are substantially similar within the United States and elsewhere throughout the world. As a matter of respect for the rich and diverse customs practiced among our business relations internationally, permissive conduct may differ somewhat in accordance with applicable policy or upon guidance from the business unit's Ethics Officer and Legal Department.
Gifts, Gratuities, and Business Courtesies to U.S., State, and Local Government Employees
Federal, state and local government departments and agencies are governed by laws and regulations concerning acceptance by their employees of entertainment, meals, gifts, gratuities, and other things of value from firms and persons with whom those government departments and agencies do business or over whom they have regulatory authority. It is the policy of Lockheed Martin to comply strictly with those laws and regulations.
Federal Executive Branch Employees
Lockheed Martin employees are prohibited from giving anything of value to federal Executive Branch employees, except as follows:
Federal Legislative and Judiciary Branches, and State and Local Government Employees
Employees of the federal Legislative and Judiciary Branches and employees of state and local government departments or agencies are subject to a wide variety of different laws and regulations. These laws and regulations and Corporate Policy Statements pertaining to them must be consulted prior to offering such employees anything of value.
Business Courtesies to Non-Government Persons
Meals, Refreshments and Entertainment
Lockheed Martin employees are prohibited from offering or giving tangible gifts (including tickets to sporting, recreational, or other events) having a market value of $100.00 or more, to a person or entity with which the Company does or seeks to do business, unless specifically approved by his or her supervisor, and the business unit's Ethics Officer or the Corporate Office of Ethics and Business Conduct.
Business Courtesies to Foreign Government Personnel and Public Officials
The Company may be restricted from giving meals, gifts, gratuities, entertainment, or other things of value to personnel of foreign governments and foreign public officials by the Foreign Corrupt Practices Act and by laws of other countries. Employees must obtain prior Legal Department approval where the hospitality (i.e., meal, gift, gratuity, entertainment or other thing of value) to be given is not clearly permissible under the Hospitality Guidelines and Matrix maintained by the Legal Department.
Employees must discuss such situations with Legal Counsel...
Steer Clear of Conflicts of Interest and Know the Rules About Employing Former Government Officials
Playing favorites or having conflicts of interest -- in practice or appearance - runs counter to the fair treatment to which we are all entitled. Avoid any relationship, influence, or activity that might impair, or even appear to impair, your ability to make objective and fair decisions when performing your job. There are extensive conflict of interest laws and regulations regarding the employment or use of former military and civilian government personnel. These rules extend to contact or negotiations with current government employees to discuss their potential employment by the Company or their use as consultants or subcontractors. Conflict of interest laws and regulations must be fully and carefully observed. When in doubt, consult corporate and company policies and procedures, and share the facts of the situation with your supervisor, Legal Department, Human Resources, or Ethics Officer.
When in doubt, share the facts of the situation with your supervisor, Legal Department, Human Resources or Ethics Officer
Here are some ways a conflict of interest could arise:
Maintain the Integrity of Consultants, Agents, and Representatives
Business integrity is a key standard for the selection and retention of those who represent Lockheed Martin. Agents, representatives, or consultants must certify their willingness to comply with the Company's policies and procedures and must never be retained to circumvent our values and principles. Paying bribes or kickbacks, engaging in industrial espionage, obtaining the proprietary data of a third party without authority, or gaining inside information or influence are just a few examples of what could give us an unfair competitive advantage in a government procurement and could result in violations of law.
Protect Proprietary Information
Proprietary Company information may not be disclosed to anyone without proper authorization. Keep proprietary documents protected and secure. In the course of normal business activities, suppliers, customers, and competitors may sometimes divulge to you information that is proprietary to their business. Respect these confidences.
Keep proprietary documents protected and secure.
Obtain and Use Company and Customer Assets Wisely
Proper use of Company and customer property, electronic communication systems, information resources, material, facilities, and equipment is your responsibility. Use and maintain these assets with the utmost care and respect, guarding against waste and abuse, and never borrow or remove them from Company property without management's permission. Be cost-conscious and alert to opportunities for improving performance while reducing costs. While these assets are intended to be used for the conduct of Lockheed Martin's business, it is recognized that occasional personal use by employees may occur without adversely affecting the interests of the Company. Personal use of Company assets must always be in accordance with corporate and company policy -- consult your supervisor for appropriate guidance and permission.
All employees are responsible for complying with the requirements of software copyright licenses related to software packages used in fulfilling job requirements.
Do Not Engage in Speculative or Insider Trading
In our role as a multinational corporation and a publicly owned company, we must always be alert to and comply with the security laws and regulations of the United States and other countries.
... we must always be alert...
It is against the law for employees to buy or sell Company stock based on material, non-public "insider" information about or involving the Company. Play it safe: don't speculate in the securities of Lockheed Martin when you are aware of information affecting the Company's business that has not been publicly released or in situations where trading would call your judgment into question. This includes all varieties of stock trading such as options, puts and calls, straddles, selling short, etc. Two simple rules can help protect you in this area: (1) Don't use non-public information for personal gain. (2) Don't pass along such information to someone else who has no need to know.
This guidance also applies to the securities of other companies (suppliers, vendors, subcontractors, etc.) for which you receive information in the course of your employment at Lockheed Martin.
For More Information:
In order to support a comprehensive Ethics and Business Conduct Program, Lockheed Martin has developed education and communication programs in many subject areas.
These programs have been developed to provide employees with job-specific information to raise their level of awareness and sensitivity to key issues.
Interactive Video Training Modules are available on the following topics:
|Antitrust Compliance||Kickbacks & Gratuities|
|Domestic Consultants||Labor Charging|
|Drug-Free Workplace||Leveraging Differences (Diversity)|
|Environment, Health and Safety||Material Costs|
|Ethics Organizational||Conflicts of Interest|
|Export Control||Procurement Integrity|
|Foreign Corrupt Practices Act||Product Substitution|
|Government Property||Record Retention|
|Harassment in the Workplace||Security|
|Insider Trading||Software License Compliance|
|International Consultants||Truth in Negotiations Act|
|International Military Sales|
The current list of Interactive Video Compliance Training Modules and Corporate Policy Statements relating to the above topics and others can be accessed via the Lockheed Martin Information Network at http://pageone.global.lmco.com/ or obtained from your supervisor.
Warning Signs - You're On Thin Ethical Ice When You Hear...
"Well, maybe just this once..."
"No one will ever know..."
"It doesn't matter how it gets done as long as it gets done."
"It sounds too good to be true."
"Everyone does it."
"Shred that document."
"We can hide it."
"No one will get hurt."
"What's in it for me?"
"This will destroy the competition."
"We didn't have this conversation."
You can probably think of many more phrases that raise warning flags. If you find yourself using any of these expressions, take the Quick Quiz on the following page and make sure you are on solid ethical ground.
Quick Quiz - When In Doubt, Ask Yourself...
Are my actions legal?
Am I being fair and honest?
Will my action stand the test of time?
How will I feel about myself afterwards?
How will it look in the newspaper?
Will I sleep soundly tonight?
What would I tell my child to do?
How would I feel if my family, friends, and neighbors knew what I was doing?
If you are still not sure what to do, ask... and keep asking until you are certain you are doing the right thing.
Our Goal: An Ethical Work Environment
We have established the Office of Vice President -- Ethics and Business Conduct to underscore our commitment to ethical conduct throughout our company.
This office reports directly to the Office of the Chairman and the Audit and Ethics Committee of the Board of Directors, and oversees a vigorous corporatewide effort to promote a positive, ethical work environment for all employees.
Our Ethics Officers operate confidential Ethics HelpLines at each operating company, as well as at the corporate level. You are urged to use these resources whenever you have a question or concern that cannot be readily addressed within your work group or through your supervisor.
Contact the Ethics Office
In addition, if you need information on how to contact your local Ethics Officer -- or wish to discuss a matter of concern with the Corporate Office of Ethics and Business Conduct -- you are encouraged to use one of the following confidential means of communication:
For the Hearing or Speech Impaired: 800-441-7457
|Write:||Office of Ethics and Business Conduct|
Lockheed Martin Corporation
P.O. Box 34143
Bethesda, MD 20827-0143
When you contact your Company Ethics Officer or the Corporate Office of Ethics and Business Conduct: